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entitled 'Student Loans: Federal Web-based Tool on Private Loans Would
Pose Implementation Challenges and May Be Unnecessary' which was
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
September 2010:
Student Loans:
Federal Web-based Tool on Private Loans Would Pose Implementation
Challenges and May Be Unnecessary:
GAO-10-990:
Contents:
Letter:
Appendix I: Briefing Slides:
Appendix II: Comments from the Department of Education:
Appendix III: GAO Contact and Staff Acknowledgments:
Abbreviations:
FFEL: Federal Family Education Loan:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 29, 2010:
The Honorable Tom Harkin:
Chairman:
The Honorable Michael B. Enzi:
Ranking Member:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
The Honorable George Miller:
Chairman:
The Honorable John P. Kline:
Ranking Member:
Committee on Education and Labor:
House of Representatives:
Student loans play a key role in ensuring postsecondary access for
millions of students each year. In fiscal year 2009, students and
their families borrowed $90 billion in federal student loans to help
pay the cost of postsecondary education. Traditionally, these loans
have been available through two programs: the William D. Ford Federal
Direct Loan Program (Direct Loan), in which the federal government
provides loans directly to students through their schools, and the
Federal Family Education Loan Program (FFEL), in which private lenders
provide loans guaranteed by the federal government. However, the
Health Care and Education Reconciliation Act of 2010 terminated the
authority to make new FFEL loans after June 30, 2010, and all
federally guaranteed loans are now originated under the Direct Loan
Program.[Footnote 1]
While private lenders no longer provide federally guaranteed student
loans, they may continue to provide private loans--estimated at nearly
$12 billion in 2008-2009--which are not federally subsidized. Although
federal loans comprise the majority of loans used to defray
educational expenses, private student loans serve as a source of
supplemental or alternative funding. For example, in 2007-2008, an
estimated 14 percent of undergraduates obtained private student loans.
Unlike federal loans, which have statutorily fixed interest rates and
flexible repayment terms, interest rates for private loans vary based
upon factors such as a borrower's credit score. These loans typically
offer borrowers fewer protections and benefits than federal loans.
Given the variety of options available, some observers have questioned
whether borrowers have sufficient information to help them make
informed decisions about student loans.
In this report, we respond to a mandate in the Higher Education
Opportunity Act[Footnote 2] requiring GAO to study the feasibility of
developing a national clearinghouse of federal and private student
loans on the Department of Education's (Education) Web site. We
addressed the following questions: (1) What are some options for
establishing a tool on Education's Web site that provides real-time
information on federal and private student loans, and what is the
perceived need for such a tool? (2) What challenges would Education
need to address in implementing such a tool?
We briefed your staff on the results of our analysis on August 25 and
26, 2010, and this report formally conveys the information provided
during the briefing (see app. I for briefing slides). In summary, we
found:
* Education has a range of options for providing prospective borrowers
with a Web-based tool containing real-time information--such as
interest rates and loan terms--on federal and private student loans,
but such a tool may be unnecessary. Providing information on private
student loans also may not align with Education's role in
administering and promoting federal student aid.
* To implement such a tool, Education would have to address several
challenges--including securing a high rate of lender participation and
ensuring completeness, accuracy, and objectivity of information
presented--to avoid the appearance of bias or endorsement.
Furthermore, minimizing costs to the federal government would be
challenging because developing a tool would require a considerable
investment, and many stakeholders ruled out a system funded by lenders.
While it would be feasible for Education to establish a student loan
tool on its Web site, the need for such a new source of information is
questionable. Since all federal student loans are now originated
through the Direct Loan Program, students no longer have to choose a
lender for federal loans. In addition, information on both federal and
private loans is already available from resources such as financial
aid offices and existing Web-based loan comparison tools. Furthermore,
any perceived need for a federal tool must be weighed against the
investment required of Education and the considerable challenges
inherent in implementation.
To identify options for establishing a tool on Education's Web site
and challenges to implementation, we interviewed officials from
Education, the Federal Trade Commission, the Securities and Exchange
Commission, and the Federal Reserve Board. We also conducted semi-
structured interviews with representatives from four privately
operated, Web-based student loan comparison tools; three organizations
that represent student loan borrowers; five higher education
associations; seven private lenders, including three that provide loan
servicing and one affiliated with a guaranty agency; one guaranty
agency with no lender affiliation; and FICO. We also interviewed
financial aid officials from five schools and a group of students from
one school. We selected this nongeneralizable sample to represent a
mix of 2-year and 4-year public and private (not-for-profit and for-
profit) institutions in various geographic locations. In addition, we
reviewed the content and structure of four Web-based student loan
comparison tools to gain a better understanding of various approaches
Education could pursue. We also reviewed relevant guidance, federal
laws, and regulations.
We conducted this performance audit from November 2009 to August 2010
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
We provided a draft copy of this report to Education for review and
comment. In written comments, Education agreed with our findings.
Education also provided technical comments, which we incorporated as
appropriate. Education's comments appear in appendix II.
We are sending copies of this report to relevant congressional
committees, the Secretary of Education, and other interested parties.
In addition, this report will be available at no charge on GAO's Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff members who made key
contributions to this report are listed in appendix III.
Signed by:
George A. Scott:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Briefing Slides:
Student Loans: Federal Web-based Tool on Private Loans Would Pose
Implementation Challenges and May Be Unnecessary:
Briefings for the Senate Committee on Health, Education, Labor, and
Pensions and the House Committee on Education and Labor:
August 2010:
Overview:
* Research Objectives;
* Scope and Methodology;
* Summary of Findings;
* Background;
* Findings;
* Concluding Observations.
Research Objectives:
In response to a mandate in the Higher Education Opportunity Act[A]
requiring GAO to study the feasibility of developing a national
clearinghouse of federal and private student loans on the Department
of Education's (Education) Web site, we addressed the following
questions:
1. What are some options for establishing a tool on Education's Web
site that provides real-time information on federal and private
student loans, and what is the perceived need for such a tool?
2. What challenges would Education need to address in implementing
such a tool?
[A] Pub. L. No. 110-315, title XI, § 1123, 122 Stat. 3078, 3506 (Aug.
14, 2008).
Scope and Methodology:
To address our research objectives, we interviewed:
* Officials from Education, the Federal Trade Commission, the
Securities and Exchange Commission, and the Federal Reserve Board.
* Representatives of 7 private lenders, including 3 that provide loan
servicing and 1 affiliated with a guaranty. agency; and
representatives of 1 guaranty agency with no lender affiliation.
* Financial aid officials from 5 schools; and a group of students at
one school. We selected this nongeneralizable sample to represent a
mix of 2-year and 4-year public and private (not-for-profit and for-
profit) institutions in various geographic locations.
* Representatives of organizations that represent student loan
borrowers; higher education associations; trade associations that
represent lenders, servicers, and guaranty agencies; 4 Web-based
student loan comparison tools; and FICO.
In addition, we:
* reviewed 4 Web-based student loan comparison tools;
* reviewed relevant federal laws, regulations, and guidance; and;
* conducted our work from November 2009 to August 2010, in accordance
with generally accepted government auditing standards.
Summary of Findings:
Education has a range of options for providing prospective borrowers
with a Web-based tool containing real-time information—such as
interest rates and loan terms—on federal and private student loans,
but such a tool may be unnecessary.
Education would have to address several challenges to implement such a
tool, including:
* securing lender participation;
* ensuring completeness, accuracy, and objectivity of information
presented; and;
* minimizing costs to the government.
Background:
The Federal Government Is Students' Primary Source of Education Loans:
During fiscal year 2009, the federal government provided $90 billion in
federal student loans to almost 11 million students and their families.
Federal loans include Stafford Loans (subsidized and unsubsidized) to
students and PLUS Loans to parents and graduate students.
Historically, these loans have been available under two programs:
* the William D. Ford Federal Direct Loan Program (Direct Loan),
under which the government originates the loans directly, and;
* the Federal Family Education Loan Program (FFEL), under which
private lenders originated loans guaranteed by the government.
As of July 1, 2010, all Stafford and PLUS Loans are originated through
the Direct Loan Program.[A]
[A] Health Care and Education Reconciliation Act of 2010, Pub. L. No.
111-152, title II, § 2201, 124 Stat. 1029, 1074 (Mar. 30, 2010).
Table: Federal Student Loans Have Fixed Interest Rates Set by Statute:
Loans disbursed 7/1/2010 to 6/30/2011: Stafford (subsidized and
unsubsidized);
Borrower eligibility: Students must be enrolled at least half-time.
Subsidized loans require demonstration of financial need;
Annual loan limits[A]: Dependent undergraduates: $5,500 - $7,500;
Annual loan limits[A]: Independent undergraduates: $9,500 - $12,500;
Annual loan limits[A]: Graduate students: $20,500;
Interest rates: Subsidized Fixed 4.5%; Unsubsidized Fixed 6.8%.
Loans disbursed 7/1/2010 to 6/30/2011: PLUS;
Borrower eligibility: Parents of dependent undergraduate students or
graduate students who are enrolled at least half-time. Borrowers
cannot have a negative credit history;
Cost of attendance minus any other financial aid received.
Interest rates: Fixed 7.9%.
Source: Department of Education.
[A] Limits vary depending on student's year in school.
[End of table]
Private Loans Are a Secondary Source of Funding for Students:
While private lenders no longer originate federally guaranteed student
loans through the FFEL Program, they continue to provide private loans—
which are not federally subsidized—as a supplement or an alternative
to federal student loans.
An estimated 14 percent of undergraduate students obtained private
loans in 2007-2008.[A]
However, data suggest that borrowers' use of private student loans has
recently decreased.
* According to preliminary data from the College Board, borrowers
obtained an estimated $11.9 billion in private student loans in 2008-
2009, a 50 percent reduction from the prior academic year.
* Tightening credit markets and recent increases in federal loan
limits may explain some of the decline.
[A] GAO analysis of Education's 2008 National Postsecondary Student
Aid Study.
Lenders Apply Underwriting Criteria to Determine Borrower Eligibility
for Private Loans:
Lenders may use a variety of factors—or underwriting criteria—to
determine borrower eligibility for private loans and to set interest
rates and terms.
* Factors may include a borrower's credit score, program length (e.g.,
2-year versus 4-year), type of school, school graduation rates, and
school cohort default rates.
The inclusion of different factors, and their relative importance in
making loan decisions, vary by lender.
Lenders consider information about their underwriting practices to be
proprietary.[A]
[A] For more information, see GAO, Higher Education: Factors Lenders
Consider in Making Lending Decisions for Private Education Loans, GAO-
10-86R (Washington, D.C.: Nov. 17, 2009).
Table: Federal and Private Loans Differ in Important Ways:
Borrower eligibility:
Federal loans: At least half-time enrollment in an eligible program;
PLUS loan borrowers must not have an adverse credit history;
Private loans: Enrollment in an eligible program; risk-based;
determined based on factors such as a borrower's credit history,
school choice, and presence of cosigner.
Interest rates:
Federal loans: Fixed, set by statute[A];
Private loans: Usually variable; determined based on borrower
characteristics and market-rates.
Repayment options:
Federal loans: Flexible options, including postponing repayment;
Private loans: Few, if any, flexibilities.
Federal oversight:
Federal loans: Department of Education;
Private loans: FTC and banking regulators.
Source: Department of Education and Federal Trade Commission.
[A] Stafford loans disbursed between October 1,1992 and June 30, 2006
had variable rates, adjusted annually. The federal government pays the
interest on subsidized Stafford loans while the borrower is in school
and during a 6-month grace period. In contrast, borrowers are
responsible for paying all interest on unsubsidized Stafford and PLUS
loans.
[End of table]
Prospective Borrowers May Turn to Several Different Sources of
Information to Help Them Evaluate Their Student Loan Options:
Education's Web site provides information on federal student loans and
financial literacy topics related to evaluating loan options.
Prospective borrowers may also seek guidance from schools' financial
aid offices, some of which maintain lists of specific lenders the
institution recommends—known as preferred lender lists.
Several private organizations have developed Web-based tools that
allow prospective borrowers to shop for private loans by comparing
interest rates, fees, and terms offered by participating lenders.
These tools vary in the number and type of lenders that participate.
As a result of amendments to the Truth in Lending Act, lenders are now
required to provide prospective borrowers with private loan
disclosures-—including information on loan rates and terms—-and inform
them that they may qualify for federal student aid. These disclosures
were required starting in February 2010.[A]
[A] The Higher Education Opportunity Act amended the Truth in Lending
Act. See 15 U.S.C. § 1638(e).
[End of section]
Finding 1: Student Loan Tool—Options:
Education Has a Range of Options for Providing Real-Time Information
on Student Loans:
With the elimination of loan originations under FFEL and the move to
the Direct Loan program, borrowers will no longer have to choose a
lender for their federal loans.
Education could include information about federal loans in any tool it
might establish that provides real-time information about private
loans.
* Could highlight federal loan options and encourage borrowers to
exhaust federal loans before obtaining private loans.
Option 1: Comprehensive List of Private Lenders:
* Would provide borrowers with a directory of current private lenders
and their contact information.
* May include a simple search feature narrowing the list by borrower
characteristics, like school type and location, and lender
characteristics, such as geographic region covered.
Figure: Contact information for potential lenders:
[Refer to PDF for image: illustration]
Lender A:
Address:
1001 Finance Center, Suite 201:
Boston, MA 02125:
Contact information:
Phone: (233) 555-2224:
Fax: (233) 555-2223:
Email: loanofficer@lendera.net.
Lender B:
Address:
1120 Lender Way Suite 723:
Portland, ME 04103:
Contact information:
Phone: (811) 555-5565:
Fax: (811) 555-5545:
Email: studentloans@lenderb.com:
Lender C:
Address:
1001 Private Loan Cir., 25th Floor:
Dallas, TX 75283:
Contact information:
Phone: (374) 555-1120:
Fax: (374) 555-1006:
Email: loaninfo@lenderc.net:
[End of figure]
Option 2: Tool with General Rates and Terms for Private Loans:
* Could display a range of available interest rates in various
formats, as well as such terms as total cost, repayment period, fees,
monthly payment, and future benefits.
* May facilitate comparison shopping by providing borrowers with
specific information on loan products from multiple lenders.
Figure: Basic information on loan rates and terms:
[Refer to PDF for image: illustration]
Lender A:
Starting Interest: 11%;
Monthly payment: $137.75;
First payment: December 2010;
Total payments: 120;
Total cost (as low as): $16,530.
Lender B:
Starting Interest: 8%;
Monthly payment: $95.57;
First payment: December 2010;
Total payments: 180;
Total cost (as low as): $17,201.
Lender C:
Starting Interest: 6.5%;
Monthly payment: $87.11;
First payment: December 2010;
Total payments: 180;
Total cost (as low as): $15,680.
Lender D:
Starting Interest: 7%;
Monthly payment: $116.11;
First payment: December 2010;
Total payments: 120;
Total cost (as low as): $13,933.
[End of figure]
Option 3: Customized Tool That Helps Match Borrowers to Private Loans:
* Could match borrowers' unique characteristics to lender-specific
criteria.
* Would likely require lenders to provide underwriting criteria on an
ongoing basis.
* Could request borrowers to enter personally identifiable information
and would likely need to obtain a borrower's credit score.
Figure: Detailed personal information (Personal, academic, and
financial information; requested loan amount):
[Refer to PDF for image: illustration]
Custom tool matches loans to borrowers:
Custom loan offers:
1. Borrower creates account and enters information.
2. System pulls borrower's credit scores.
3. Loan offers matched to borrower's personal data.
4. Borrower views loan offers side by side.
5 Borrower deals directly with lender for loan.
[End of figure]
Table: Options for Providing Real-Time Information on Student Loans
Vary in Design and Complexity:
Key feature: Could highlight federal student loan options;
List of private lenders: [Check];
General rates and terms: [Check];
Customized tool: [Check].
Key feature: Provides listing of lenders and contact information;
List of private lenders: [Check];
General rates and terms: [Check];
Customized tool: [Check].
Key feature: Could include sort capability based on basic borrower
information;
List of private lenders: [Check];
General rates and terms: [Check];
Customized tool: [Check].
Key feature: Facilitates comparison shopping by displaying loan terms
and rates;
List of private lenders: [Empty];
General rates and terms: [Check];
Customized tool: [Check].
Key feature: Collects borrowers' personally identifiable information
and obtains credit score;
List of private lenders: [Empty];
General rates and terms: [Empty];
Customized tool: [Check].
Key feature: Matches individual borrowers to loan products for which
they are eligible;
List of private lenders: [Empty];
General rates and terms: [Empty];
Customized tool: [Check].
Source: GAO analysis.
[End of table]
Finding 1: Student Loan Tool—-Need:
A Federal Tool Could Serve as a Trusted Resource for Borrowers:
Students and several stakeholders we interviewed said a federal tool
may be perceived by potential borrowers as more neutral and
trustworthy than private sector tools.
Officials from two schools stated that a federal tool could be used to
help borrowers better understand loan options and educate them about
common loan terminology, requirements, and responsibilities.
Students and most stakeholders we interviewed generally agreed that
financial literacy is a challenge for borrowers.
Several Stakeholders Questioned Whether a Federal Tool Would Add Value
beyond Currently Available Resources:
Several lenders and higher education associations stated that existing
Web-based loan comparison tools provide a useful service to help
borrowers assess their private loan options and questioned whether a
tool on Education's Web site would be duplicative.
Education officials noted that schools are often students' primary
source of information and already provide students various
informational resources on options for financing their education.
Recent Legislative Changes Have Increased Transparency of Information
about Private and Federal Student Loans:
Education officials and two lenders said the new Truth in Lending Act
disclosure forms provide a transparent and uniform way for borrowers
to compare private loans.
* Borrowers receive the first of three disclosures when they
apply or receive a solicitation for a private student loan.
Education officials and several other stakeholders anticipate that
originating all federal loans through the Direct Loan program will
lessen the confusion some students have had about the differences
between federal and private loans, since private lenders will no
longer make federal loans.
Finding 1: Student Loan Tool-—Education's Role:
Providing Information on Private Loans May Not Align with Education's
Role:
Education administers federal student aid and has no regulatory
authority over private student loans.
Education cannot endorse particular private lenders or loan products.
Education officials expressed concern that:
* Providing private loan information could encourage use of those
loans, which do not have the same protections and benefits as federal
loans.
* In a customized tool, the department would be placed at unnecessary
risk by, having to protect borrowers' personally identifiable
information for a purpose over which Education has no regulatory
authority.
[End of section]
Finding 2: Implementation-—Lender Participation:
Most Stakeholders Said Securing Widespread Lender Participation Could
Be a Considerable Challenge:
Education officials and many other stakeholders said the department
would need a high level of lender participation in order to be
unbiased and avoid the appearance of endorsement.
* Education officials and a few stakeholders said a comprehensive tool
would need to include national and smaller lenders, such as credit
unions, state-based organizations, and schools.
* Representatives of two loan comparison tools cited challenges they
faced in securing lenders' participation.
Most lenders we spoke with said they would be unlikely to participate
in a federal tool or would have to carefully evaluate the option.
* All lenders expressed concern about a customized model that would
require them to provide loan underwriting criteria to Education.
However, about half of stakeholders said providing customized
information would be more useful than the other options.
Finding 2: Implementation—-Information Management:
Most Stakeholders Said Education Would Face Challenges in Ensuring the
Completeness and Accuracy of Information Presented:
Education officials and several other stakeholders said that the
agency could not ensure that the loan rates and terms lenders would
provide are the most current.
* The market is fluid; interest rates may change frequently and
lenders often enter or exit the market.
* Many stakeholders, including representatives of two existing loan
comparison tools, said that it would be particularly difficult to
maintain accurate information in a tool that provides customized loan
options.
Education officials expressed concern that the department's
credibility could be damaged if it could not guarantee that borrowers
received lenders' advertised rates and terms.
Most Stakeholders Said Education Would Face Challenges in Ensuring the
Objectivity of Information Presented:
Several stakeholders said the wide variety of interest rates (e.g.,
fixed vs. variable) and loan terms makes it difficult to present
information in a way that facilitates objective comparison.
Four lenders and a few other stakeholders said the way the tool
displays loan information (e.g., sorted alphabetically, by interest
rate) could influence which loans look preferable.
* Research on survey development has shown people are more likely to
only look at the first few items on a list and can be overwhelmed if
presented with too many choices.
* One financial aid official said the first lender listed on the
school's preferred lender list received the highest loan volume.
Finding 2: Implementation—-Costs:
Most Stakeholders Said Funding a Federal Student Loan Tool Would Be
Costly:
Education officials said developing a tool and keeping information
current would require a considerable investment in staff and
technology resources, regardless of the tool's complexity. For
example, the agency would have to cover the cost of contracting to
develop a tool and build a secure system to house it.
Education officials and two lenders noted that constantly evolving
loan rates and terms would make the tool expensive to maintain.
In a customized tool, Education would incur a cost for obtaining each
borrower's credit score, according to agency officials and several
stakeholders.
Education officials and many stakeholders ruled out a system funded by
lenders.
* For example, most lenders said that charging fees could shut out
smaller lenders that do not have the volume to justify the expense.
A few stakeholders said schools would object to paying for a loan tool
on Education's Web site.
* For example, one school financial aid official said that many small
schools could not afford the service.
[End of section]
Concluding Observations:
Providing real-time information to help borrowers make informed
decisions about federal and private student loans is a laudable goal.
While it would be feasible for Education to establish a student loan
tool on its Web site, the need for such a new source of information is
questionable.
* Originating all federal student loans through the Direct Loan
program eliminates the need for students to choose a lender for
federal loans.
* Information on federal and private loans is available through
existing resources, including financial aid offices and several Web-
based loan comparison tools.
Finally, any perceived need must be weighed against the investment
required for Education to establish such a tool and the considerable
challenges inherent in its implementation.
[End of section]
Appendix II: Comments from the Department of Education:
United States Department Oe Education:
Office Of Postsecondary Education:
The Assistant Secretary:
1990 K St. N.W.
Washington, DC 20006:
[hyperlink, http://www.ed.gov]
[The Department of Education's mission is to promote student
achievement and preparation for global competitiveness by fostering
educational excellence and ensuring equal access]
September 17, 2010:
George A. Scott:
Director, Education, Workforce, and Income Security Issues:
United States Government Accountability Office:
Washington, DC 20548:
Dear Mr. Scott:
Thank you for giving the U.S. Department of Education (Department) the
opportunity to review and comment on the Government Accountability
Office (GAO) draft report entitled "STUDENT LOANS: Federal Web-based
Tool on Private Loans Would Pose Implementation Challenges and May Be
Unnecessary" (GAO-l0-990). Your letter includes these findings:
* Education has a range of options for providing prospective borrowers
with a Web-based tool containing real-time information—such as
interest rates and loan terms—on federal and private student loans,
but such a tool may be unnecessary. Providing information on private
student loans also may not align with Education's role in
administering and promoting federal student aid.
* To implement such a tool, Education would have to address several
challenges—-including securing a high rate of lender participation and
ensuring completeness, accuracy, and objectivity of information
presented—-to avoid the appearance of bias or endorsement.
Furthermore, minimizing costs to the federal government would be
challenging because developing a tool would require a considerable
investment, and many stakeholders ruled out a system funded by lenders.
The Department agrees with your findings but has technical comments
(see enclosure). The Department remains committed to continuing to
increase college access, quality, and completion. As you note, student
loans play a key role in ensuring postsecondary access for millions of
students every year. In this regard, we appreciate your research and
analysis related to the feasibility and usefulness of a Web-based
informational tool on federal and private student loans.
Sincerely,
Signed by:
[Illegible] for:
Eduardo M. Ochoa:
Enclosure:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO contact:
George A. Scott (202) 512-7215 or scottg@gao.gov:
Staff Acknowledgments:
Debra Prescott (Assistant Director) and Rebecca Woiwode (Analyst-in-
Charge) managed this assignment. Jennifer Cook, Paola Bobadilla, and
Tranchau (Kris) Nguyen made significant contributions in all facets of
the work. In addition, Jean McSween and Patrick Dudley provided
methodological support; James M. Rebbe provided legal assistance;
Susan Aschoff provided writing assistance; and James Bennett and Mimi
Nguyen provided graphics for the report.
[End of section]
Footnotes:
[1] Health Care and Education Reconciliation Act of 2010, Pub. L. No.
111-152, title II, § 2201, 124 Stat. 1029, 1074 (Mar. 30, 2010).
[2] Pub. L. No. 110-315, title XI, § 1123, 122 Stat. 3078, 3506 (Aug.
14, 2008).
[End of section]
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